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Privacy Policy

This Privacy Policy explains how Liernin Enterprises LTD ("Fun Bet", "we", "us") collects, uses, stores, shares and protects personal data when you access or use the Fun Bet version of our online casino services provided through funsbeti.com, including any mirror sites and access via VPN from the United Kingdom.

It applies to registered players, prospective players, and other visitors who browse or interact with funsbeti.com, whether you create an account, place bets, contact support, or simply view our pages.

For users in the UK and other relevant jurisdictions, we handle your information in line with the UK General Data Protection Regulation ("UK GDPR"), the UK Data Protection Act 2018, and, where applicable, the EU GDPR and Mexican data protection law for affected users.

Effective date: 1 January 2026

Who We Are

The Fun Bet profile relates to the "Fun Bet" online casino services made available through funsbeti.com. These services are operated by:

  • Controller / Operator: Liernin Enterprises LTD
  • Legal entity type: Private company limited by shares (LTD)
  • Registered / legal address: Marshall Islands (offshore corporate address; detailed street address and postal code are not specified in the currently available public information).
  • Gaming licence: PAGCOR (Philippine Amusement and Gaming Corporation) Licence No. 18-0022, for international online casino operations (non-UK). This licence does not constitute a UK Gambling Commission licence, and Fun Bet is treated as a grey-market offering for UK residents.

For data protection purposes, Liernin Enterprises LTD is the controller of your personal data in relation to the Fun Bet profile on funsbeti.com.

Data Protection Contact

We have designated an internal person or team responsible for privacy compliance (Data Protection Officer or equivalent data protection function).

  • Data Protection Officer / Privacy Lead: Liernin Enterprises LTD - Data Protection Officer
  • Contact channels: Please use the secure messaging, live chat or other support tools made available within your funsbeti.com account or on the website and clearly mark your message "For the attention of the Data Protection Officer" or "Privacy request".
  • Telephone and postal contact: As of February 2025, no dedicated telephone number or detailed postal mailing address for privacy matters has been published. Where required, we will provide additional contact details through your account area or via the website and update this Privacy Policy accordingly.

What Personal Data We Collect

We collect and process only the data that is necessary for operating Fun Bet on funsbeti.com, fulfilling our contractual obligations, and complying with applicable laws. Depending on how you interact with us, we may collect the following categories of data:

  • Identification and contact data: Full name, username, date of birth, country of residence, address (where provided), email address, mobile/phone number (if supplied), identity document details (e.g. passport or ID number, copies, issuing country), and other KYC/AML information required under anti-money-laundering and player verification rules.
  • Account and behavioural data: Account registration details, login history, session identifiers, language preferences, communication preferences, bets placed, game rounds, wins and losses, bonus usage, transaction history, responsible gambling settings, self-exclusion choices (where available), complaints or support tickets, and records of interactions with our customer support.
  • Technical and usage data: IP address, approximate geolocation derived from your IP or device settings, device identifiers, browser type and version, operating system, referral URLs, clickstream data, pages visited, time and date of visits, and other log data generated by your device when you access funsbeti.com or related mirror domains.
  • Payment and financial data: Partial payment card details (card type, masked number, expiry date), e-wallet identifiers, bank account information where required for withdrawals, payment transaction IDs, deposit and withdrawal history, chargeback information, and verification details from payment providers. We do not store your full card details where this is handled by PCI-compliant payment processors.
  • Verification and risk data: Information obtained during KYC/AML checks, sanctions screening, fraud and risk assessments (including device fingerprints, risk scores, or flags generated by third-party anti-fraud tools), copies of documents you upload (ID, proof of address, source-of-funds documents), and internal notes regarding risk reviews.
  • Marketing and preference data: Records of your consents to receive marketing communications, your subscription and opt-out history, interactions with marketing emails or push notifications, bonus or campaign participation, and your preferences regarding channels (email, SMS, in-site messages).
  • Cookies and similar technologies: Unique cookie identifiers, session tokens, web beacons, pixel tags, local storage objects and similar tracking technologies set by us or by authorised third parties for functionality, analytics, and advertising purposes (see the "Cookies & Tracking Technologies" section).
  • Special categories of data: We do not intentionally collect sensitive categories of data (such as health, religion or political opinions). However, responsible gambling interactions may indirectly reveal health or vulnerability information that you voluntarily provide (e.g. when you explain a gambling-related harm situation to support). Such information is handled with heightened care and only where strictly necessary.

Legal Basis for Processing

We process your personal data only where we have a valid legal basis under the UK GDPR (and, where applicable, EU GDPR and relevant Mexican privacy law). Depending on the specific activity, our legal bases include:

  • Performance of a contract: We need to process certain data to create and administer your Fun Bet account on funsbeti.com, verify your eligibility, accept deposits, process bets, pay out winnings, provide customer support, and otherwise fulfil the Terms & Conditions you agree to when you register and use our services.
  • Compliance with legal obligations: We are required by anti-money-laundering (AML) and counter-terrorist-financing (CTF) regulations, financial reporting rules, tax laws, and gambling regulatory requirements in our licensing jurisdiction(s) (including under PAGCOR Licence No. 18-0022 and any applicable local laws) to carry out identity checks, monitor transactions, report suspicious activity, maintain records, and comply with requests from competent authorities. For Mexican players, we also observe applicable obligations derived from the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP).
  • Legitimate interests: We process data to secure our platform, prevent fraud and abuse, investigate suspicious or abusive behaviour, ensure the integrity of games, maintain business records, improve our services, perform analytics and statistics, and protect our legal rights and interests. When relying on legitimate interests, we balance our interests against your rights and reasonable expectations and implement safeguards to minimise any impact on your privacy.
  • Consent: We rely on your explicit consent for certain activities, such as sending marketing communications by email/SMS, using non-essential cookies or similar technologies for advertising, and, where required, accessing device information beyond what is strictly necessary for service provision. You may withdraw your consent at any time (see "Your Rights").
  • Vital interests and legal claims: In rare circumstances, we may process data to protect your vital interests or those of another person (for example, when we are contacted about a serious risk of harm), or to establish, exercise or defend legal claims in court or in front of regulatory or alternative dispute resolution bodies in the Philippines, Mexico, the UK or other relevant jurisdictions.

Where local law requires a different or additional legal basis (for example, certain consent requirements under Mexican LFPDPPP), we will ensure that we meet those requirements for affected users.

Purpose of Processing

We process your personal data for clearly defined purposes. The main purposes include:

  • Provision of casino services: To register and manage your Fun Bet account, verify your identity and age, accept deposits, process bets and game play, pay out winnings, provide bonuses and promotions, and deliver the gaming services offered on funsbeti.com.
  • Customer support and communication: To respond to your questions, complaints or feedback via live chat, email or internal messaging; to send service messages (for example about account changes, security alerts, responsible gambling tools or updates to this Privacy Policy); and to keep records of our interactions for quality and training purposes.
  • Regulatory compliance and risk management: To carry out KYC/AML checks, monitor transactions, detect suspicious or irregular behaviour, enforce our Terms & Conditions, manage chargebacks, assist law-enforcement or competent authorities, and comply with our obligations under gambling, AML and data protection law in relevant jurisdictions (including the UK, Philippines and, where applicable, Mexico and the EU/EEA).
  • Personalisation and service improvement: To understand how users interact with funsbeti.com, analyse performance and usability, personalise content (such as game recommendations or language settings), test new features, fix bugs, and generally improve the quality, stability and security of our services.
  • Marketing and promotions: With your consent where required, to send you marketing communications about Fun Bet offers and promotions available on funsbeti.com, to analyse the effectiveness of campaigns, and to avoid sending you irrelevant or excessive messages. We may also use aggregated or pseudonymised data to understand general trends.
  • Fraud prevention and platform security: To prevent, detect and investigate fraud, misuse of accounts, bonus abuse, money laundering, and other unlawful or unethical activities; to protect the integrity of our games; to secure systems and networks; and to apply sanctions or account limitations where justified.
  • Legal defence and business operations: To maintain accurate records for audit and accounting, to manage potential disputes, to respond to claims or regulatory investigations, and to support corporate transactions or restructuring (subject to appropriate safeguards and, where required, your consent).

Disclosure & Sharing

We do not sell your personal data. However, we share data where necessary for the operation of Fun Bet on funsbeti.com, for compliance, or with your consent. Categories of recipients include:

  • Group entities and associated brands: Other entities within the Liernin Enterprises LTD group or related brands (such as sister sites described in research reports) may receive data for internal administrative purposes, consolidated reporting, risk management and where needed to deliver shared services, subject to contractual safeguards.
  • Payment service providers and financial institutions: Banks, card schemes, e-wallet providers, payment gateways, and other payment intermediaries that process deposits, withdrawals, chargebacks and anti-fraud screening. These providers act as independent controllers or processors depending on their role and applicable law.
  • Technical and infrastructure providers: Hosting providers, content delivery networks, IT support companies, cloud service providers, analytics tools, communication platforms (for email, SMS or in-site messages), identity verification services, and anti-fraud/AML tools that support the operation, security and performance of funsbeti.com.
  • Regulators and public authorities: Gambling regulators (including PAGCOR), financial intelligence units, tax authorities, law-enforcement bodies, courts and similar authorities in jurisdictions where we have legal obligations or where a request is lawfully made. For UK residents, this does not include the UK Gambling Commission in its capacity as regulator of Fun Bet, as the brand is not UKGC-licensed; however, your data may still be processed in connection with UK ICO or other authorities for data protection purposes.
  • Professional advisers: Lawyers, auditors, compliance consultants and other professional advisers who assist us in meeting our legal, financial and regulatory obligations, bound by confidentiality obligations.
  • Marketing and affiliate partners: Subject to your consent where required, carefully selected marketing partners, affiliates, and advertising networks may use cookies or other identifiers to show you relevant offers relating to Fun Bet on funsbeti.com, to track campaign performance, or to prevent fraud and abuse of promotions.
  • Alternative dispute resolution (ADR) bodies: In the event of a dispute, your data may be shared with ADR entities or bodies in the Philippines or other relevant jurisdictions that handle complaints about gambling operators. Note that for UK players, independent UK dispute bodies such as IBAS do not cover Fun Bet.
  • Corporate transactions: In connection with a merger, acquisition, restructuring, or sale of all or part of our business. In such cases, we will ensure that any new controller continues to respect this Privacy Policy or provides a comparable level of protection and, where required, we will inform you and give you options.

Where we share data with processors (service providers that act on our instructions), we enter into written data processing agreements requiring them to use your data only for the specified purposes and to implement appropriate security measures.

International Transfers

Because Liernin Enterprises LTD is registered in the Marshall Islands and operates under a PAGCOR licence in the Philippines, and because we use international service providers, your personal data may be transferred to and processed in countries outside of the United Kingdom and the European Economic Area (EEA), including:

  • Marshall Islands: As our registered corporate location and a potential administrative centre for certain back-office functions.
  • Philippines: As our primary gambling licensing jurisdiction under PAGCOR Licence No. 18-0022 and a potential location for operational teams, support, risk and compliance.
  • European Union / EEA countries: Where infrastructure, hosting or service providers are located in EU/EEA Member States or where EU-based partners process data on our behalf.
  • Other third countries: For example, where cloud providers, payment processors, or support centres operate from the United States or other non-EEA countries.

Some of these countries may not provide the same level of data protection as the UK or the EEA. When we transfer personal data from the UK or EEA to a country that is not subject to an adequacy decision, we implement appropriate safeguards, such as:

  • Standard Contractual Clauses (SCCs): We rely on the UK and/or EU Standard Contractual Clauses where appropriate, combined with technical and organisational measures to protect your data.
  • Contractual and organisational safeguards: Robust contractual obligations, data protection addenda, access controls, encryption, strict data-access policies, and internal governance measures designed to ensure an equivalent level of protection.
  • Risk assessments: Transfer impact assessments and due-diligence on our service providers' security practices and legal environment, particularly when using suppliers in countries with broad government access powers.

We do not rely on the former EU-US Privacy Shield framework, which has been invalidated, as a legal basis for transfers. Where new adequacy decisions or frameworks are adopted (for example, UK international data transfer mechanisms), we may rely on them to legitimise transfers.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, to comply with legal and regulatory requirements, to resolve disputes, and to enforce our agreements. Retention periods depend on the type of data and the context of processing:

  • Account and identification data: As a general rule, we retain core account information (e.g. name, contact details, KYC documentation, transaction history) for the duration of your active account and for up to five (5) years after account closure or your last transaction, whichever is later, to comply with AML/CTF and record-keeping obligations and to defend against legal claims. In some jurisdictions, including under certain AML rules, we may be legally required to keep records for longer.
  • Transactional and payment data: Records of deposits, withdrawals, bets, wins and losses, and payment transactions are typically kept for at least five (5) years from the date of the relevant transaction, or longer where required by tax, accounting or regulatory rules.
  • Customer support and communications: Support tickets, chat logs and correspondence related to disputes, complaints or responsible gambling interactions are generally retained for up to five (5) years from resolution, unless a longer period is necessary due to ongoing investigations or legal proceedings.
  • Marketing data: Information about your marketing consents and preferences is retained while you remain subscribed and for a limited period (typically up to two (2) years) after you opt out, solely to keep proof of your previous consent and to ensure we respect your choices.
  • Technical and log data: Security logs, device identifiers and other technical data are kept for shorter periods where feasible (for example from a few days to twelve months), unless they need to be retained longer for security investigations, fraud prevention or regulatory reasons.

When data is no longer required, we will either securely delete or irreversibly anonymise it so that it can no longer be linked to you. If you request erasure, we will also consider whether we must continue to retain certain data to comply with our legal obligations or legitimate interests (see "Your Rights").

Your Rights

Depending on your place of residence and the applicable law (including UK GDPR, EU GDPR and, where relevant, Mexican privacy law such as the Federal Law on Protection of Personal Data Held by Private Parties - LFPDPPP), you may have the following rights in relation to your personal data:

  • Right of access: To obtain confirmation as to whether we process your personal data and, if so, to receive a copy of your data and certain information about how we use it.
  • Right to rectification: To have inaccurate or incomplete personal data corrected. You can update some details directly in your funsbeti.com account; for other changes (such as correcting KYC documents), please contact support.
  • Right to erasure ("right to be forgotten" / cancellation): To request deletion of your personal data where, for example, it is no longer necessary for the purposes for which it was collected, you have withdrawn consent (where consent was the legal basis), or you have successfully objected to processing. This right may be limited where we must retain data for legal or regulatory reasons (e.g. AML/CTF requirements).
  • Right to restriction of processing: To request that we restrict the processing of your data in certain circumstances, such as when you contest the accuracy of the data, when processing is unlawful but you prefer restriction to deletion, or when we no longer need the data but you require it for legal claims.
  • Right to object: To object at any time, on grounds relating to your particular situation, to processing based on our legitimate interests, including profiling. You also have an absolute right to object to processing for direct marketing purposes, which includes profiling related to marketing.
  • Right to data portability: To receive certain personal data in a structured, commonly used and machine-readable format and to transmit that data to another controller, where technically feasible and where processing is based on consent or contract and carried out by automated means.
  • Right to withdraw consent: Where we rely on your consent (for example for marketing or certain cookies), you may withdraw that consent at any time without affecting the lawfulness of processing before withdrawal. You can manage marketing consents in your account settings or by using the unsubscribe mechanisms in our communications.
  • Rights under Mexican law (ARCO rights): If you are protected by Mexican privacy law, you may exercise additional or equivalent rights known as ARCO rights (Acceso, Rectificación, Cancelación y Oposición - Access, Rectification, Cancellation and Opposition) in line with the LFPDPPP and its Regulations. We will process such requests in accordance with the specific timelines and requirements established by Mexican law, while aiming to harmonise them with our general 30-day response timeframe.

How to Exercise Your Rights

  • Submission of requests: Please contact us through the secure channels available in your funsbeti.com account or via the contact options indicated on the site, clearly stating that your message is a "Data protection / privacy request" and specifying the right you wish to exercise.
  • Verification: We may ask for additional information to verify your identity and ensure that we do not disclose data to an unauthorised person, especially for access, portability or erasure requests.
  • Response timeframe: We aim to respond to all valid requests within 30 days of receipt. In complex cases, or where we receive multiple requests, this period may be extended by up to a further 30 days, as permitted by law. For requests subject to Mexican LFPDPPP, we will respect any shorter statutory deadlines where applicable.
  • Fees: Requests are handled free of charge. However, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded, excessive or repetitive, in line with applicable law.
  • Limitations: Certain rights may be limited, for example where disclosure would adversely affect the rights of others, interfere with ongoing investigations or legal proceedings, or where we are legally required to retain certain data (such as AML records).

Cookies & Tracking Technologies

funsbeti.com uses cookies and similar technologies to operate Fun Bet, improve performance, and provide a better user experience. Cookies are small text files that are stored on your device when you visit our website.

Types of Cookies We Use

  • Strictly necessary / functional cookies: Session cookies and other essential cookies that enable core functions such as logging in, navigating the site, managing your account, maintaining your betting slip, and ensuring security. These cookies are required for the site to work and cannot be switched off in our systems.
  • Preference cookies: Cookies that remember your language, region, or other preferences so that we can tailor the site to your needs when you return.
  • Analytics and performance cookies: First-party or third-party cookies used to collect aggregated information about how visitors use funsbeti.com (for example, pages visited, time spent, error messages). This helps us understand and improve the performance and usability of the site.
  • Advertising and targeting cookies: Cookies, pixels or similar technologies set by us or by authorised marketing partners to deliver relevant adverts, track the effectiveness of campaigns, prevent bonus abuse, and limit how many times you see a particular ad.

Managing Cookies

  • Browser settings: Most web browsers allow you to manage or delete cookies through their settings (for example, blocking all cookies, accepting only certain types, or prompting you before cookies are stored). If you block strictly necessary cookies, some parts of funsbeti.com may not function properly.
  • In-site controls: Where available, we provide cookie or privacy settings on funsbeti.com that allow you to manage non-essential cookies and change your preferences at any time.
  • Third-party opt-outs: For certain analytics or advertising cookies, you can also manage preferences directly with the relevant third party or via industry opt-out tools, where available in your region.

For more details on specific cookies and their lifetimes, please consult the cookie or privacy settings panel on funsbeti.com when available.

Data Security

We take the security of your personal data seriously and implement appropriate technical and organisational measures designed to protect it against unauthorised access, loss, misuse, alteration or disclosure. While no system can be guaranteed as 100% secure, our measures include:

  • Encryption in transit and at rest: Use of up-to-date cryptographic protocols (such as TLS 1.2 or higher) to protect data transmitted between your browser and our servers, and encryption or equivalent safeguards for sensitive data stored within our systems or those of our trusted service providers.
  • Access controls and authentication: Strict role-based access controls, need-to-know principles, multi-factor authentication for administrative accounts where practicable, secure password policies, and regular review of access rights to limit who can view or process personal data.
  • Network and infrastructure security: Firewalls, intrusion-detection and prevention systems, anti-malware tools, system hardening, security monitoring, and segregation of environments to reduce the risk of unauthorised access or lateral movement.
  • Application security: Secure development practices, code reviews, vulnerability scanning, penetration testing (where appropriate), and prompt remediation of identified issues to minimise exploitable weaknesses in our platform.
  • Organisational measures and training: Internal policies on data protection, confidential information and acceptable use; staff training and awareness programmes; background checks where appropriate; and contractual confidentiality obligations for employees and contractors.
  • Incident detection and response: Procedures to detect, assess and respond to potential data breaches or security incidents, including containment, investigation, remediation, documentation, and notification to affected users and relevant authorities when required by law.

Although no formal public certifications (such as ISO 27001 or SOC 2) are currently specified in the available information about Fun Bet on funsbeti.com, our security controls are designed to align with recognised industry best practices and international standards where reasonably practicable.

Complaints & Contacts

If you have questions about this Privacy Policy, our use of your personal data, or if you wish to lodge a complaint, you can contact us and, if necessary, escalate your concerns to supervisory authorities.

Contacting Us

  • Primary contact: Please contact us through the customer support options available on funsbeti.com (for example, live chat or secure messaging), indicating that your request relates to privacy or data protection and is addressed to the Data Protection Officer.
  • Language and clarity: To help us respond efficiently, please provide your full name, username, contact details, a clear description of your request or complaint, and any supporting documentation.
  • Response timeframe: We aim to acknowledge your complaint and provide an initial response within a reasonable time, and in any case within 30 days where practicable, depending on the complexity of the matter.

Escalation to Supervisory Authorities

If you are not satisfied with our response or believe that we are processing your personal data in breach of applicable law, you may have the right to lodge a complaint with a data protection authority:

  • United Kingdom: Information Commissioner's Office (ICO). You can find contact details and instructions at www.ico.org.uk. The ICO is generally the relevant authority for UK-based data subjects in relation to UK GDPR and the Data Protection Act 2018.
  • European Union / EEA: If you are located in an EU/EEA Member State, you may contact your local data protection authority. Details for each authority are available on the European Data Protection Board (EDPB) website.
  • Mexico: For users protected by Mexican privacy law, you may lodge a complaint with the National Institute for Transparency, Access to Information and Personal Data Protection (INAI), which oversees compliance with the LFPDPPP.
  • Philippines: As our gambling operations are licensed under PAGCOR and certain processing activities may take place in the Philippines, you may also contact the National Privacy Commission (NPC) in the Philippines if local data protection law applies to you.

Please note that while Fun Bet is not licensed by the UK Gambling Commission and is considered a grey-market operator for UK residents (with no access to UK gambling ADR bodies such as IBAS), your rights concerning the processing of personal data remain protected under applicable data protection laws as described in this Privacy Policy.

Updates

We may update this Privacy Policy from time to time to reflect changes in our processing activities, legal or regulatory developments, industry practices, or improvements to our services. When we make material changes, we will take appropriate steps to inform you.

  • Notification methods: We may notify you of updates by:
    • Displaying a prominent notice or banner on funsbeti.com;
    • Sending an in-account message or email to the address associated with your Fun Bet profile; and/or
    • Providing alerts in your account dashboard.
  • Advance notice for significant changes: Where changes materially affect your rights or how we process your data (for example, new purposes or new categories of recipients), we will, where reasonably practicable, provide at least 30 days' advance notice before the new version takes effect, unless immediate changes are required by law or for security reasons.
  • Your options: If you do not agree with an updated Privacy Policy, you may close your account and stop using funsbeti.com. Continued use of the services after the effective date of the changes will constitute your acknowledgement of the updated policy to the extent permitted by law.

Last updated: January 2026

We encourage you to review this Privacy Policy periodically to stay informed about how Fun Bet, operated via funsbeti.com by Liernin Enterprises LTD, protects your personal data.